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Accounting period changes affecting CFCs and corporations exiting a consolidated group.(controlled foreign corporations)
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The Tax Adviser
- Article date:
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January 1, 2008
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Copyright informationCOPYRIGHT 2008 American Institute of CPA's. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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In Rev. Proc. 2007-64, the Service has modified the scope provision set forth in Rev. Proc. 2006-45 for corporations that exit a consolidated group and request consent to change their annual accounting periods. Rev. Proc. 2007-64 also modifies the terms and conditions relating to recordkeeping and book conformity for controlled foreign corporations (CFCs) that have a majority U.S. shareholder year (as defined in Sec. 898(c)(3)) and change to a one-month deferral year under Sec. 898(c)(2) or a 52- or 53-week tax year that references a one-month deferral year.
Corporation Exiting a Consolidated Group
Rev. Proc. 2007-64 modifies the scope of Rev. Proc. 2006-45 to clarify ...
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